K. CH. PRASAD vs SMT. J.VANALATHA DEVI AND ORS.

The Supreme Court upheld the rejection of a Revision Petition concerning the maintainability of prosecution against the appellant under Section 120(b) read with Sections 467 and 471 IPC, affirming the High Court's view that Section 197 of the Criminal Procedure Code does not apply as the appellant, a public servant, is removable by a competent authority without government sanction. The Court clarified that nationalization does not automatically confer protection under Section 197 if the removal process does not require government approval. The appeal was dismissed, affirming the lower courts' decisions.